Notice 2023-63, which was released on September 8 and can be found in the 2023-39 Internal Revenue Bulletin, marks the initial substantial guidance regarding the modifications to section 174. These changes were introduced as part of the Tax Cuts and Jobs Act with the intention of funding other tax reductions.
A&M Tax with co-host Wolters Kluwer recently held a Virtual Coffee Talk (VCT) discussing key takeaways from Notice 2023-63, including potential issues that could arise, surprising inclusions, and whether taxpayers should plan to rely on the Notice before regulations are promulgated.
During the session, Kathleen King, Managing Director at A&M Tax, shared her perspectives on the new software development rule within the guidance. Her insights on Section 41 and Section 174 have been recently quoted in Tax Notes. To gain a deeper understanding, click here:
Read the Full Article
Thai Customs Introduces Revised Reward System: Key Implications for Business
July 10, 2026
New Thai Customs rewards rule reshapes officer allocations but preserves core incentives, keeping enforcement pressure high. Reassess exposure now, especially on valuation, tariff codes, origin claims, and related-party payments.
Navigating Q2 2026: Essential Income Tax Accounting Insights
July 8, 2026
Explore key Q2 2026 income tax accounting developments, including ASC 740 and IAS 12 implications from Pillar Two compliance, U.S. court rulings, tariff uncertainty, state tax conformity, and global tax changes.
Delhi High Court Rules that Reimbursement of Salary Cost for Seconded Employees Constitutes FTS Where Home Entity Retains Lien and Overarching Control
July 7, 2026
The Delhi High Court (HC), on June 18, 2026, in Ernst & Young U.S. LLP (EY US) has, inter alia, ruled that in the given facts, EY US retained ‘lien’ over seconded employees in India and cost-to-cost reimbursements of such seconded employees were taxable as Fees for Technical Services (FTS) under both Section 9(1)(vii) of the Income-tax Act, 1961 (Act), and Article 12 of the India–US Tax Treaty (Tax Treaty).
A&M Tax – Monthly Recap of EU and Dutch Tax Developments
July 6, 2026
The “Monthly Recap” is A&M’s monthly newsletter providing a concise overview of EU and Dutch tax developments.
